Harmonized Tariff Schedule

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CBP’s $1 Billion De Minimis Announcement and the Procedural Refund Problem

Informal Entries, Section 321, and Why “Refunds Later” Is a Procedural Assumption U.S. Customs and Border Protection recently announced that it has collected more than $1 billion in duties following the suspension of duty-free de minimis treatment under Section 321. The announcement highlights the scale and speed with which duties are now being collected on […]

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The IEEPA Tariff Refund Question No One Is Asking

Informal Entries, Section 321, and a Procedural Gap in the Case Law Recent litigation over tariffs imposed under the International Emergency Economic Powers Act (IEEPA) has focused on a recurring procedural question: if the tariffs are ultimately held unlawful, can importers recover the duties they paid?  In addressing that question, courts have declined to halt

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The U.S. Chocolate Tariff-Rate Quota: A Compliance Perspective (Plus a Debate About Candy)

Trade compliance teaches humility. Sometimes that humility comes from parsing the Uruguay Round; sometimes it comes from your spouse in the candy aisle at H-E-B. Let’s set the stage. As an update to my video on this subject in 2024, CBP’s Quota Bulletin 26-216 2026 for the 2026 quota year reminds us that the United

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Stoic and Zen Thinking for Stronger Trade Compliance

Calm realism, disciplined process, and freedom through precision In trade, as in life, denial is expensive. The Stockdale Paradox teaches that we must confront the brutal facts of our situation while maintaining unwavering faith in our ability to endure and succeed. Stoicism meets Zen here: both demand clear perception without attachment to outcomes. The Stoic

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What CBP Is Looking For in Your Classification Justification (and What Happens If You Don’t Have It)

When Customs and Border Protection (CBP) asks how you arrived at your tariff classification, they are not making polite conversation. They want to know whether your decision was based on a reasoned analysis or a lucky guess. A classification justification is the documented reasoning behind your chosen Harmonized Tariff Schedule (HTS) code. It is one

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How to Classify New or Unique Products with No Clear HTS Code

If you’re importing something cutting-edge, niche, or just plain weird, chances are you’ve stared at the Harmonized Tariff Schedule and thought: Where the hell does this go? You’re not alone. In fact, many importers dealing with innovative or hybrid products find themselves stuck in HTS purgatory. Their products are too specific for broad categories, too

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